March 22, i960
Hr. James L. I'.cGoffin
Executive Secretary
Board of Trustees
Plumbing and Pipe-fitting Industry
Lloyd Building
Seattle, Washington
Dear Jim:
Enclosed herewith find a subpoena duces tecum in the caso
of Klones vs. Local 265, et al.
The original, which is being served upon you, is to bo
turned over to the Clerk on the norning of the hearing.
I put you under subpoena in view of the fact that I would
not want you criticized for voluntarily participating in
a matter of interest primarily to Local 265.
Very truly yours,
James J. Holthan
JJMrgs
Dnclosure
/
File, ^-^>*-*-o ^
MEMO SHEETS
Talaphon* CohtowhIIhi wnh^ 7^ c-^"^~ (^.
^JJ/o
^^"7
V~>?-
rom i7a
•
ion, is and fob
snohomish count*.
GEOHGE {CLONES d/b/a N0DE2N PLUMBING
& heating,
Plaintiff,
DHITSD ASSOCIATION OF JCUBHSXMSN *
APPRENTICES CI . LUH3ING & PI.
FITTINa INDUSTRY OF TflS UNITED STATES
and CANADA, LOCAL NO. 265, et al.
Defendants.
NO. 6587I
3 TECUM
To:
You are hereby conoanded to be and appear before me, ALENE STEFFSN, a Notary
Public in and for the State of Washington, residing at Everett, at 9s30 o'clock
. M., at the offices of the County Clerk, Snohomish County Courthouse, Everett,
Washington, on the 24th day of March, i960, and then and there to testify as a
witness on behalf of the defendants in a certain cause now pending in the Superior
Court of the State of Washington for Caohoaish County wherein George Klones d/b/a
Modem Plumbing & Heating is plaintiff, and United Association of Journeymen &
Apprentices of the Plumbing and Pipefitting Industry of the United States and
Canada, Local :io. 265, st al, are defendants, and to remain in attendance until
discharged, and L.
And you are further directed and commanded to bring with you the following
papers and documents now in your possession or under your control, viz.:
1. All reports made by Modern Plumbing Z\ "floating with yourself as
proprietor thereof to the Hoard of Trustees, 3taiey of Washington Plumbing
and Pipefitting Industry, vacation plan and health and welfare program,
being report Form No. 1084, for each and every cialendor month during the
year of 1956.
2. Any copy or original of any memorandum* contract or agreement
between George Klones d/b/a Modern Plunbir ,ng and Stewart and
Potter Homes, Inc., in offect during the calendar yVar of 1958.
3. Any copy or original of any memorandum,! contract or agreement
between Oe. ones d/b/a Moder tling \and Peter oolamoasen
governing contracts during the year of 1958 or 19^9, with pe.. r reference
to cotistruction being done on or about :day, < ]), in t
vicir-ity of 8l3t Ilacs West and 230th . ynnwood, Cnohonrtah
ity, Washington, area.
4. Any copy or original of any aeaorandum^ contract or agreement between
George Klones d/b/a Modem numbing »ating and . • tordon, loneral
•, concornlng the coastructio; es at or near 222nd and 84th West
in the T/toonds-Iynnwood area 0 ah County, on.
5. And any and all contracts made and entered into by and between
George Klones d/b/a Kodern rlumbing I Heating and any individual journeyman or
apprentice, artisan or machanic, contemplating the performance of manual work or
labor, the purchaoe of materials and the rental of tools, trucks and any and other
types of equipment at the premises of construction being done for the account of
Stewart and Potter Homes, Inc., Peter Golamonsen, andAx rdon, in any area
located in Snohomish County, Washington, during the years of 1958 and 1959.
6. Any and all records evidencing purchases made by George Klones d/b/a
Kodern ilumbing ?< Heating or Oeorge Klones, of materials, fixtures, equipment,
appliances, tools, trucks, for the years 1957, 1958 and 1959, indicating the
source of said purchases, the materials purchased, and the prices paid therefor.
7. Any and all contracts, memorandum or agreements for construction
performed for the account of any firm, person, associate or corporation in the
Snohomish County area for the year 195b or 1959, other than those specifically
requested in 2, 3 and k above.
8. Any and all job sets or job records of any type kept or maintained
by George Klones d/b/a Kodern PlUBbifig Seating in reference to work done for
account of Wdoa, Peter Golamonsen and Stewart and Potter Homes, Inc.?
all individual Inter vice fores Mo. 10*»0 or other Internal Revenue
Service tax return forms made either by George Klones as an individual or as the
proprietor of Kodern ilumbing I itlag for the years of 1956, 1 58 and
1959, inclusive of estimates.
9. Any and all employment tax returns evidencing payment of employer's
contributions and/or taxec to the Department of Labor and Industries, otate of
Washington, the Jmployment Security Service, .otate of Washington, the Tiaployer
Contribution Section, ristrict "Jiractcr, Internal Revenue Service, ". B, Treasury
Department, ZaeoM, Washington, evidencing payment or necessary employer's reports
required by the Industrial Insurance Act of t so of Washington, the
Employment Security Act of the State of Washington, or the Internal Revenue Act
of the United States of Ar.erica, for the years 1956, 1957, 1958, 1959.
Witness my hand and official seal this .day of March, I960.
• •••'•• __.
Notary Public in and for the State of
Washington, residing at Everett, Washington.
- 2 -
IN THE SOFER'.< WS OF THE STA iiASHINQTCK, IN AND FOR
SNOHOMISH COUNT!
GEORGE XLOHES d/b/a MODERN PLUMBING
& HEATING,
Plaintiff,
vs.
UNITED ASSOCIATION I .INEXMSW fc
APPRENTICES 0 ..
. :U5TRY OF
and CAtJADA, LOCAL NO. 265, et al.
leftndantHi
'.v. 6 5 8 5 1
not: l examination
bsfobs thial
To: Georce Klonea,
and to: Robert W. Maxwell, Esq., his attorney.
YOU, AND EACH OF YOU, WILL PLEAS ROE that the testimony of George
Klonee, plaintiff herein, will be taken on Oral Anamination Before Trial, at the
instance and request of Leonard A. Rise, United Brotherhood of Carpenter and
Jointers of America, Local 562; International Association of Sheet I'etal Workers,
Local 193, and International Brotherhood of Electrical Workers, Local 191,
defendants herein, in the above entitled and numbered action, before ALSO STEFFEN,
Notary Public, or some other Notary Public, at the office of the Clerk, Snohomish
County Courthouse, Everett, '-'awMngton, on the 24th day of Karen, I960, commencing
at the hour of 9:30 o'clock A. K, on that duyj the said Oral Examination of said
witness at said time and place to bo subject to continuance or adjournment from
time to time or place to place until completed.
Ibis testimony upon oral examination will be taken on the ground and for the
reason the said George Clones will give evidence material to the establishment of
the defendants' case.
DATED this day of March, I960.
Office and Post Office Address:
3028 Wetmore Avenue,
Everett, Washington.
Stanley L. Conroy, Esq.,
Attorney for above named defendants.
-
In the Superior Court of the State of Washington
for the
Countyof -_!!___•_______
KLOUS d/b/a MODEM
Plaintiff I No.. *
vs.
er.no*, et ai, [ Subpoena Duces Tecum
Defendant.
The State of Washington to-***£****&•-********* «*—"If*!!* Greeting:
.otter Hoeee, Inc.,
You are hereby commanded to appear in the court room of the Superior Court of the State of
Washington, Dept. No Room No , Judge II _*_*__' '___ Presiding,
«. 29th , . :=-- ,_ CO 9*30 on the __ day of , 19 , at
o'clock in the___*_*__r_l , then and there to give evidence in a certain cause
wherein .JSMLgglLlga^ Plaintiff______
, Doited Association of Journeymen and Apprentices of the Fln-fbiag a
«__raj-_nii«--«"IrfftB€i7"6TTHi-0^-^-T_M
and you are further directed and commanded to bring with you the following papers and documents
now^yo^^ses|io^r^_g yo^go,ng,oh^:1«^^Any •eeoras-iua, contract, or agreeeent
"odern ilunbinf i IT—ting, governing any construction requirements of said corpora-the
construction arid purchased of necessary naterialo involved in said construction
oYThe~a__tege4"85"TM_wo^~core"oFlel_o
at or near QOth and 213th Streets, iJdnonds, Gaohooioh Countyt Waaninston, oore
^€lci&arly~ae5crl3^^
of Ifoveoher, 1958, and filed in the above-entitled cause.
and to remain in attendance on said Court until discharged, and HEREIN FAIL NOT at YOUR PERIL.
Seattle Ilurch 60
Dated at Washington, this day of , 19
—i53r.e_rii-.--^xtbe__r
Defendants
Attorney of Record for
507 Lyon Building,
P. O. Address County, Wash.
TWs blank is guaranteed against successful alteration, which guaranty is insured in LLOYD'S, Lcndcn Pat. Pend.
Washington Legal Blank Co. (Subpoena Duces Tecum) Form No. 171. printing date S-28-S8
No.
In the
SUPERIOR COURT
of the State of Washington
for the
County of .
( Subpoena Duces Tecum
Plaintiff—
vs.
(
Defendant
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S 41
r
LAW OFFICES
STANLEY L. CDNRDY
3020 WETMORE AVENUE
March 14, 1960 everett. Washington
ALPINE 9-1414
ALPINE 9-7124
Mr. James J. Molthan
Attorney at Law
607 Third Avenue
Seattle 4, Washington
Re: KLones vs. United Association
Dear Mr. Molthan:
I spent approximately an hour with a number of the officers of the union
involved, including Mr. Cyr, and they decided not to contribute one cent by
way of appeasement.
It now seems that we had better win this case, and I would like to talk to
you about it some day when you have time. It is set for March 29th and
there is no reason to believe it will not come on for trial that day.
Please give me a call and let me know when a convenient time for a confer
ence will exist.
STANLEY L. CONROY
SLC:sb
1TWBK /ak
IN THE SUPERIOR COURT OP THE STATE OP WASHINGTON
POR SNOHOMISH COUNTY
GEORGE KLONES d/tya MODERN
PLUMBING & HEATING,
Plaintiff, NO.65851
vs. SETTING CALENDAR
.
UNITED ASSOCIATION OP JOURNEYMEN
& APPRENTICES OF THE PLUMBING &
PIPE-PITTING INDUSTRY OP THE UNITED
STATES AND CANADA, LOCAL 265; et al,
Defendants.
TO 1 James J. Molthan and Stanley L. Conroy, Attorneys for
Defendants and
TO: Clerk of the above entitled Court:
Please take notice that the issue of faot in this cause
will be brought on to be set on the 5th day of February, i960,
at the hour of 9:30 a.m., and the Clerk is requested to note
this cause on the calendar in Department No. of the
above Court in the Court Room thereof in the Court House,
Everett, Washington.
F. ROBERT LEE
Of Kumm, Maxwell, Petersen & Lee,
Attorneys for Plaintiff.
552 Central Building
Seattle 4, Washington
Main 2-8460
NATIONAL LABOR RELATIONS BOARD
NINETEENTH REGION
327 Logan Building, 500 Union Street
Seattle 1, Washington
January 8, I960
Telephone MUlual 2-3300
Ext. 560
Mr. James J. Molthan
607 Third Avenue
Seattle h, Washington
Dear Mr. Molthan:
We are returning herewith at your request, the Petition for
Determination of Jurisdiction which you submitted to this office.
Very truly yours,
Attorney
Ends.

Click tabs to swap between content that is broken into logical sections.

March 22, i960
Hr. James L. I'.cGoffin
Executive Secretary
Board of Trustees
Plumbing and Pipe-fitting Industry
Lloyd Building
Seattle, Washington
Dear Jim:
Enclosed herewith find a subpoena duces tecum in the caso
of Klones vs. Local 265, et al.
The original, which is being served upon you, is to bo
turned over to the Clerk on the norning of the hearing.
I put you under subpoena in view of the fact that I would
not want you criticized for voluntarily participating in
a matter of interest primarily to Local 265.
Very truly yours,
James J. Holthan
JJMrgs
Dnclosure
/
File, ^-^>*-*-o ^
MEMO SHEETS
Talaphon* CohtowhIIhi wnh^ 7^ c-^"^~ (^.
^JJ/o
^^"7
V~>?-
rom i7a
•
ion, is and fob
snohomish count*.
GEOHGE {CLONES d/b/a N0DE2N PLUMBING
& heating,
Plaintiff,
DHITSD ASSOCIATION OF JCUBHSXMSN *
APPRENTICES CI . LUH3ING & PI.
FITTINa INDUSTRY OF TflS UNITED STATES
and CANADA, LOCAL NO. 265, et al.
Defendants.
NO. 6587I
3 TECUM
To:
You are hereby conoanded to be and appear before me, ALENE STEFFSN, a Notary
Public in and for the State of Washington, residing at Everett, at 9s30 o'clock
. M., at the offices of the County Clerk, Snohomish County Courthouse, Everett,
Washington, on the 24th day of March, i960, and then and there to testify as a
witness on behalf of the defendants in a certain cause now pending in the Superior
Court of the State of Washington for Caohoaish County wherein George Klones d/b/a
Modem Plumbing & Heating is plaintiff, and United Association of Journeymen &
Apprentices of the Plumbing and Pipefitting Industry of the United States and
Canada, Local :io. 265, st al, are defendants, and to remain in attendance until
discharged, and L.
And you are further directed and commanded to bring with you the following
papers and documents now in your possession or under your control, viz.:
1. All reports made by Modern Plumbing Z\ "floating with yourself as
proprietor thereof to the Hoard of Trustees, 3taiey of Washington Plumbing
and Pipefitting Industry, vacation plan and health and welfare program,
being report Form No. 1084, for each and every cialendor month during the
year of 1956.
2. Any copy or original of any memorandum* contract or agreement
between George Klones d/b/a Modern Plunbir ,ng and Stewart and
Potter Homes, Inc., in offect during the calendar yVar of 1958.
3. Any copy or original of any memorandum,! contract or agreement
between Oe. ones d/b/a Moder tling \and Peter oolamoasen
governing contracts during the year of 1958 or 19^9, with pe.. r reference
to cotistruction being done on or about :day, < ]), in t
vicir-ity of 8l3t Ilacs West and 230th . ynnwood, Cnohonrtah
ity, Washington, area.
4. Any copy or original of any aeaorandum^ contract or agreement between
George Klones d/b/a Modem numbing »ating and . • tordon, loneral
•, concornlng the coastructio; es at or near 222nd and 84th West
in the T/toonds-Iynnwood area 0 ah County, on.
5. And any and all contracts made and entered into by and between
George Klones d/b/a Kodern rlumbing I Heating and any individual journeyman or
apprentice, artisan or machanic, contemplating the performance of manual work or
labor, the purchaoe of materials and the rental of tools, trucks and any and other
types of equipment at the premises of construction being done for the account of
Stewart and Potter Homes, Inc., Peter Golamonsen, andAx rdon, in any area
located in Snohomish County, Washington, during the years of 1958 and 1959.
6. Any and all records evidencing purchases made by George Klones d/b/a
Kodern ilumbing ?< Heating or Oeorge Klones, of materials, fixtures, equipment,
appliances, tools, trucks, for the years 1957, 1958 and 1959, indicating the
source of said purchases, the materials purchased, and the prices paid therefor.
7. Any and all contracts, memorandum or agreements for construction
performed for the account of any firm, person, associate or corporation in the
Snohomish County area for the year 195b or 1959, other than those specifically
requested in 2, 3 and k above.
8. Any and all job sets or job records of any type kept or maintained
by George Klones d/b/a Kodern PlUBbifig Seating in reference to work done for
account of Wdoa, Peter Golamonsen and Stewart and Potter Homes, Inc.?
all individual Inter vice fores Mo. 10*»0 or other Internal Revenue
Service tax return forms made either by George Klones as an individual or as the
proprietor of Kodern ilumbing I itlag for the years of 1956, 1 58 and
1959, inclusive of estimates.
9. Any and all employment tax returns evidencing payment of employer's
contributions and/or taxec to the Department of Labor and Industries, otate of
Washington, the Jmployment Security Service, .otate of Washington, the Tiaployer
Contribution Section, ristrict "Jiractcr, Internal Revenue Service, ". B, Treasury
Department, ZaeoM, Washington, evidencing payment or necessary employer's reports
required by the Industrial Insurance Act of t so of Washington, the
Employment Security Act of the State of Washington, or the Internal Revenue Act
of the United States of Ar.erica, for the years 1956, 1957, 1958, 1959.
Witness my hand and official seal this .day of March, I960.
• •••'•• __.
Notary Public in and for the State of
Washington, residing at Everett, Washington.
- 2 -
IN THE SOFER'.< WS OF THE STA iiASHINQTCK, IN AND FOR
SNOHOMISH COUNT!
GEORGE XLOHES d/b/a MODERN PLUMBING
& HEATING,
Plaintiff,
vs.
UNITED ASSOCIATION I .INEXMSW fc
APPRENTICES 0 ..
. :U5TRY OF
and CAtJADA, LOCAL NO. 265, et al.
leftndantHi
'.v. 6 5 8 5 1
not: l examination
bsfobs thial
To: Georce Klonea,
and to: Robert W. Maxwell, Esq., his attorney.
YOU, AND EACH OF YOU, WILL PLEAS ROE that the testimony of George
Klonee, plaintiff herein, will be taken on Oral Anamination Before Trial, at the
instance and request of Leonard A. Rise, United Brotherhood of Carpenter and
Jointers of America, Local 562; International Association of Sheet I'etal Workers,
Local 193, and International Brotherhood of Electrical Workers, Local 191,
defendants herein, in the above entitled and numbered action, before ALSO STEFFEN,
Notary Public, or some other Notary Public, at the office of the Clerk, Snohomish
County Courthouse, Everett, '-'awMngton, on the 24th day of Karen, I960, commencing
at the hour of 9:30 o'clock A. K, on that duyj the said Oral Examination of said
witness at said time and place to bo subject to continuance or adjournment from
time to time or place to place until completed.
Ibis testimony upon oral examination will be taken on the ground and for the
reason the said George Clones will give evidence material to the establishment of
the defendants' case.
DATED this day of March, I960.
Office and Post Office Address:
3028 Wetmore Avenue,
Everett, Washington.
Stanley L. Conroy, Esq.,
Attorney for above named defendants.
-
In the Superior Court of the State of Washington
for the
Countyof -_!!___•_______
KLOUS d/b/a MODEM
Plaintiff I No.. *
vs.
er.no*, et ai, [ Subpoena Duces Tecum
Defendant.
The State of Washington to-***£****&•-********* «*—"If*!!* Greeting:
.otter Hoeee, Inc.,
You are hereby commanded to appear in the court room of the Superior Court of the State of
Washington, Dept. No Room No , Judge II _*_*__' '___ Presiding,
«. 29th , . :=-- ,_ CO 9*30 on the __ day of , 19 , at
o'clock in the___*_*__r_l , then and there to give evidence in a certain cause
wherein .JSMLgglLlga^ Plaintiff______
, Doited Association of Journeymen and Apprentices of the Fln-fbiag a
«__raj-_nii«--«"IrfftB€i7"6TTHi-0^-^-T_M
and you are further directed and commanded to bring with you the following papers and documents
now^yo^^ses|io^r^_g yo^go,ng,oh^:1«^^Any •eeoras-iua, contract, or agreeeent
"odern ilunbinf i IT—ting, governing any construction requirements of said corpora-the
construction arid purchased of necessary naterialo involved in said construction
oYThe~a__tege4"85"TM_wo^~core"oFlel_o
at or near QOth and 213th Streets, iJdnonds, Gaohooioh Countyt Waaninston, oore
^€lci&arly~ae5crl3^^
of Ifoveoher, 1958, and filed in the above-entitled cause.
and to remain in attendance on said Court until discharged, and HEREIN FAIL NOT at YOUR PERIL.
Seattle Ilurch 60
Dated at Washington, this day of , 19
—i53r.e_rii-.--^xtbe__r
Defendants
Attorney of Record for
507 Lyon Building,
P. O. Address County, Wash.
TWs blank is guaranteed against successful alteration, which guaranty is insured in LLOYD'S, Lcndcn Pat. Pend.
Washington Legal Blank Co. (Subpoena Duces Tecum) Form No. 171. printing date S-28-S8
No.
In the
SUPERIOR COURT
of the State of Washington
for the
County of .
( Subpoena Duces Tecum
Plaintiff—
vs.
(
Defendant
ft
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nn
-
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-,
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53
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S 41
r
LAW OFFICES
STANLEY L. CDNRDY
3020 WETMORE AVENUE
March 14, 1960 everett. Washington
ALPINE 9-1414
ALPINE 9-7124
Mr. James J. Molthan
Attorney at Law
607 Third Avenue
Seattle 4, Washington
Re: KLones vs. United Association
Dear Mr. Molthan:
I spent approximately an hour with a number of the officers of the union
involved, including Mr. Cyr, and they decided not to contribute one cent by
way of appeasement.
It now seems that we had better win this case, and I would like to talk to
you about it some day when you have time. It is set for March 29th and
there is no reason to believe it will not come on for trial that day.
Please give me a call and let me know when a convenient time for a confer
ence will exist.
STANLEY L. CONROY
SLC:sb
1TWBK /ak
IN THE SUPERIOR COURT OP THE STATE OP WASHINGTON
POR SNOHOMISH COUNTY
GEORGE KLONES d/tya MODERN
PLUMBING & HEATING,
Plaintiff, NO.65851
vs. SETTING CALENDAR
.
UNITED ASSOCIATION OP JOURNEYMEN
& APPRENTICES OF THE PLUMBING &
PIPE-PITTING INDUSTRY OP THE UNITED
STATES AND CANADA, LOCAL 265; et al,
Defendants.
TO 1 James J. Molthan and Stanley L. Conroy, Attorneys for
Defendants and
TO: Clerk of the above entitled Court:
Please take notice that the issue of faot in this cause
will be brought on to be set on the 5th day of February, i960,
at the hour of 9:30 a.m., and the Clerk is requested to note
this cause on the calendar in Department No. of the
above Court in the Court Room thereof in the Court House,
Everett, Washington.
F. ROBERT LEE
Of Kumm, Maxwell, Petersen & Lee,
Attorneys for Plaintiff.
552 Central Building
Seattle 4, Washington
Main 2-8460
NATIONAL LABOR RELATIONS BOARD
NINETEENTH REGION
327 Logan Building, 500 Union Street
Seattle 1, Washington
January 8, I960
Telephone MUlual 2-3300
Ext. 560
Mr. James J. Molthan
607 Third Avenue
Seattle h, Washington
Dear Mr. Molthan:
We are returning herewith at your request, the Petition for
Determination of Jurisdiction which you submitted to this office.
Very truly yours,
Attorney
Ends.